Name of Controller: UNIX Autó és Alkatrészkereskedelmi Kft. (hereinafter referred to as: “UNIX Autó Kft.” or “Controller”)
Controller’s Address: 1139 Budapest, Frangepán utca 55-57.
Contacts: Address: 1139 Budapest, Frangepán utca 55-57. Tel: +36-1-270-8700; Fax: +36-1-270-8799;
Naming of data processing: Data processing is based on the freely given, informed and unambiguous consent of users.
Legal grounds for data processing: Having regard to Regulation (EU) 2016/679 of the European Parliament and of the Council (“General Data Protection Regulation” or GDPR) and Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, in particular Article 5 (1) thereof, Consent of the data subject.
- ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
- ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;
- ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
- ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;
- ‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law;
- ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;
- „ ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the 4.5.2016 L 119/33 Official Journal of the European Union EN framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
- ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorized to process personal data;
- ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
- ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
- ‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
- ’biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
- ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
- ‘main establishment’ means: (a) as regards a Controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the Controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; (b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;
- ‘representative’ means a natural or legal person established in the Union who, designated by the Controller or processor in writing pursuant to Article 27, represents the Controller or processor with regard to their respective obligations under this Regulation;
- ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
- ‘group of undertakings’ means a controlling undertaking and its controlled undertakings;
- ‘binding corporate rules’ means personal data protection policies which are adhered to by a Controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a Controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
- ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
- ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because: (a) the Controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority;
- ‘cross-border processing’ means either: (a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a Controller or processor in the Union where the Controller or processor is established in more than one Member State; or (b) processing of personal data which takes place in the context of the activities of a single establishment of a Controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
- ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the Controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;
- ‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council
- ‘international organization’ means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
Principles relating to processing of personal data:
Controller processes personal data lawfully and fairly, only for specific purposes, without data waste, precisely, with limited storability, confidentially and accountably, as well as transparently for the data subject.
- may only be collected for specified, explicit and lawful purposes
- may only be controlled in ways compatible with these purposes
- must be adequate and relevant
- must be limited to what is necessary
- must be accurate and, where necessary, kept up to date
- must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
- must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
Range of data processed:
The vehicle’s registration number, billing name, ZIP code, street address, mobile phone number, email address, the registration’s country code, country, county, city, vehicle identification number, manufacturer’s engine code, production date (year, month), expiry of registration certificate, expiry of green card, last mileage, average distance covered per year (km), ABS, ASR, catalytic converter, air conditioning, servo.
Data technically recorded during the operation of the system, video recording:
Data from the computer you use to log in, which are generated through the use of the website’s services and which are recorded automatically by the Controller’s system as an automatic result of technological processes. The automatically recorded data are logged automatically when you log in or off without any separate declaration or action on your part.
In the event of your shopping at one of our outlets, a video recording is made, which is stored by the Controller for 14 days for asset protection purposes.
Purpose of data processing:
If you fill in the registration form and provide your data, it enables us to prepare your loyalty card. With the loyalty card you are entitled to a 10% discount at our outlets; in case you consented to the processing of your data and you requested it, we send you a warning in a text message or email when your vehicle’s MOT test has expired. By registering you consent to receive emails on our promotions. Before registering the data, the Data Subject must be informed whether data provision is mandatory or voluntary. In the case of mandatory data processing, the legal regulation mandating it must also be indicated.
Controller may not use the personal data for any other purposes than those specified in this Article.
Period of data processing:
We inform you that the data necessary for issuing your invoice is stored by Controller for 5+2 years as mandated by law.
We inform you that the personal data you provided are processed until you submit a declaration withdrawing your consent or requesting their erasure.
We inform you that a video surveillance system is operated at our outlets for asset protection purposes, the recordings of which are erased after 14 days.
Erasure of personal data:
With regard to data provided by the you, in case you freely decide so, data are erased within 30 days of the receipt of your written request thereof. In case you use personal data unlawfully or deceptively or commit a crime, upon being informed about this, UNIX Autó Kft. may erase all your personal data at the same time as erasing your registration. A request for the erasure of personal data must be sent to the email address email@example.com. Data are erased within 30 days of the receipt of your written request, unless the law mandates otherwise. In the event of erasure, the profile data cannot be restored.
In line with your fields of interest, Controller may show personalized ads on the sites downloaded when visiting the website or may send personalized advertisements to you in email, which contain useful and interesting information for you. Advertising spaces and personalized contents are machine-selected, during their distribution no personal data are transmitted or processed, no analysis or examination of personal data is necessary.
Data processing for sending newsletters:
Fact and purpose of data processing: when registering at the webshop www.unixauto.hu the user gives preliminary consent to get electronic or printed newsletters about the service provider’s current offers at the contacts given during registration. Without registration Controller does not send advertising content. Registered users may unsubscribe from newsletters orally, electronically or by post. Newsletters may only be sent to users who accept the Privacy Statement provided on the website.
Range of data subjects: Visitors and customers who subscribe to the newsletter on the website.
Range of data processed: Date, time, last name, first name, email address, telephone number
Legal grounds of processing: Regarding newsletter subscription, Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, as well as Article 6 (1)a of Regulation EU 2016/679 (“GDPR”).
Period of data processing: Data are erased within 30 days of the receipt of the Data Subject’s written request.
Rights of data subjects in relation to data processing:
- The data subject may request access to, correction or erasure of her or his personal data or the restriction of processing
- The data subject may object to the processing of her or his personal data at the contacts given in the prospectus
- The data subject may withdraw her or his consent to the access to her or his data on the basis of the principle of portability, as well as to the processing of her or his data given in the course of newsletter subscription.
- Persons authorized to access personal data, recipients of personal data: Personal data given at the time of subscription may be processed by employees of the Controller.
Contacts of persons authorized to erase or alter personal data or restrict processing:
Email address: firstname.lastname@example.org
Possibility of modifying the data protection policy:
UNIX Autó Kft. upholds the right to unilaterally modify this data protection policy with the prior notification of data subjects. After accepting the modified data protection policy, data subjects may continue the use of the service undisturbed.
Transferring personal data:
Data processed by UNIX Autó Kft. may only be accessed by its employees (within Hungary and abroad) as well as members of its branches. As specified in Act CXII/2011, data may only be transferred and different forms of data processing connected if the data subject has given his or her explicit consent or if the law permits it, and the conditions of data processing are upheld in relation to every piece of personal data.
Cross-border transfer of data:
Personal data may be transmitted by a data Controller covered by this Act to a data Controller or processor operating in a third country, or may be transferred to a data Controller or processor operating in a third country if: a) the data subject has given his or her explicit consent, or b) the conditions laid down in legal regulations satisfied and the adequate level of protection of the personal data have been ensured in the third country during the course of the control and processing of the data transferred. You can exercise your rights in court as specified in Act CXII/2011 and in Civil Law, and you can ask for help from a Data Protection Supervisor. In case of further questions or comments please contact the operator at email@example.com.
Rights of the user and exercising them:
You may ask Controller to inform you whether your personal data is processed and if so, you can request access to your personal data that are processed.
You can view the personal data you provided in the settings of the access control system of the services, as well as on the profile pages related to individual services. You may also request information about the processing of your personal data at any time, in a registered letter with or without acknowledgement or via email at firstname.lastname@example.org. The request for information in the letter will only be regarded as authentic if based on the request you are clearly identifiable. Requests for information via email will only be regarded as authentic if it is sent from your registered email address, but this does not exclude the right of the Controller to identify you in other ways as well before giving the information.
The request for information may include the data processed by Controller, the source of these data, the purpose, legal grounds, time period of data processing, the names and addresses of data processors (if any), activities related to data processing, and in the event of the transfer of personal data the recipients and purposes of the transfer of your data. You may ask for the modification or rectification of your personal data processed by Controller. Considering the purposes of data protection, you may request the completion of incomplete personal data. You can modify personal data you provided in the settings of the access control system of the services, as well as on the profile pages related to individual services. In the event of a request for the modification of personal data, the original (erased) profile data cannot be restored. You may request the erasure of your personal data processed by the Controller.
A request for erasure may be denied (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation or (iii) for the establishment, exercise or defence of legal claims. In the event of denying a request for erasure, the Controller will notify you in every case, specifying the reason for denial. In the event of a fulfilling a request for the erasure of personal data, the original (erased) profile data cannot be restored.
You can unsubscribe from newsletters sent by Controller through the “unsubscribe” link provided in the newsletter. In the event of unsubscription Controller erases your personal data stored in the newsletter database.
You can request the restriction of the processing of personal data if you contest the accuracy of the personal data processed. If the accuracy of an item of personal data is contested by the data subject and its accuracy or inaccuracy cannot be ascertained beyond doubt, the Controller shall mark that personal data for the purpose of referencing, and the restriction only applies for the time until the accuracy of the data is ascertained. If you contest the accuracy or correctness but the inaccuracy or incorrectness cannot be ascertained beyond doubt, you can request the restriction of the processing of personal data. If the processing is unlawful and you oppose the erasure of the personal data, you can request the restriction of their use instead. You can also request the restriction of data processing if the Controller no longer needs the personal data for the purposes of the processing, but you need their processing for the establishment, exercise or defence of legal claims. You have the right to receive the personal data concerning you, which you have provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller.
You can object to the processing of your personal data if the data processing only serves the Controller’s or a third party’s legitimate interest; if the purpose of data processing is direct marketing, polling or scientific research; or if processing is done in relation to the performance of a task carried out in the public interest.
The Controller will examine the lawfulness of your objection, and if it is legitimate, stops processing the data and blocks the personal data, and notifies you and all recipients to whom it was transmitted for processing about the objection and the measures taken.
External data processors:
Controller guarantees that he will not transfer your personal data to external service providers.
Security of processing:
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
- the pseudonymisation and encryption of personal data;
- the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services
- the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
- a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
Communication of a personal data breach to the data subject and notification of a personal data breach to the supervisory authority:
In the case of a personal data breach, the Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Controller shall communicate the personal data breach to the data subject without undue delay.
Court enforcement of claims:
In the event of any infringement of his rights, the data subject may turn to court action against the Controller. The burden of proof to show compliance with the law lies with the Controller. The competent court in the lawsuit is the one to which the seat of Controller regionally belongs. Any person otherwise lacking legal capacity to be a party to legal proceedings may also be involved in such actions. When the court’s decision is in favor of the plaintiff, the court shall order the Controller to provide the information, to rectify, block or erase the data in question, to annul the decision adopted by means of automated data-processing systems, to respect the data subject’s objection, or to disclose the data requested by the data subject. The court may order publication of its decision, indicating the identification data of the Controller as well, where this is deemed necessary for reasons of data protection or in connection with the rights of large numbers of data subjects.
Controllers shall be liable for any damage caused to a data subject resulting from unlawful processing or by any breach of data security requirements. The Controller may be exempted from liability if he or she proves that the damage was caused by reasons beyond his or her control. No compensation shall be paid where the damage was caused by intentional or serious negligent conduct on the part of the aggrieved party.
I declare that I am familiar with the Data Protection Policy of UNIX Car and Spare Parts Dealing Company Ltd. (hereinafter referred to as UNIX Autó Kft.), and I am aware that UNIX Autó Kft. collects my personal data for the purposes of creating my loyalty card, and stores them to enable my discount purchases with the loyalty card. I consent that UNIX Autó Kft. should use my freely given personal data for the purposes specified by them and make them available to its branches, in line with the regulations of the Privacy Act.
I am aware that after becoming a registered partner of UNIX Autó Kft. I am entitled to request the erasure of any or all the personal and other data I provided. I accept that UNIX Autó Kft and its competent colleagues in Hungary and abroad, as well as car servicing facilities belonging to the network of UNIX Autó Kft in Hungary and abroad should be allowed to access my personal data, but these should not be transferred to other private or legal persons or organizations without legal personality. UNIX Autó Kft and its network of car servicing facilities are in no ways authorized to use the personal data given by me to transfer or use my personal data for any other purposes than those specified in the Data Protection Policy. I agree that unless I otherwise declare, UNIX Autó Kft and members of its network of car servicing facilities may inform me about promotions and new products on the email address I provided at registration